The Centers for Medicare and Medicaid Services (CMS) has released the proposed 2019 Physician Fee Schedule, including proposals to reduce documentation burdens associated with evaluation and management (E/M) services and to substitute a single “flat rate” payment for some E/M services. The proposed changes apply only to those E/M codes billed in an office setting for new and established patients (99202-99205 and 99212-99215).

The proposed changes to documentation requirements would allow physicians to choose between documenting on the basis of current guidelines for a level 2 service, documenting by time only, or documenting by medical decision making only. This would simplify documentation for billing purposes.

The proposed single flat rate would take the place of the different levels of complexity (2 through 5) currently reportable by clinicians. That means physicians would be paid the same rate for E/M services regardless of the complexity of the work a patient requires.

Overall, psychiatry would see a small increase in payment for E/M services if the proposed flat rate is made final, according to an estimate by the AMA. However, certain subspecialists and physicians who treat more complex patients would likely see a decrease in overall payment. For example, payments to addiction medicine physicians and geriatric psychiatrists for E/M services are estimated to drop by 2 and 3 percent, respectively. Rates may or may not be offset by payments for other billed services.

APA staff are analyzing the proposal and are working with member experts as well as other physician specialty and subspecialty groups in crafting a response.

“We are pleased to see the administration is taking steps to ease the administrative burdens facing physicians in their daily practice,” said APA CEO and Medical Director Saul Levin, M.D., M.P.A. “We are carefully analyzing the administration’s proposed fee schedule and especially the proposal for a single, flat-rate for office-based E/M services. Based on that analysis, we will send our comments to the administration and work with our affiliate organizations to secure appropriate payment for all psychiatrists and ensure access to care for all patients.”

The deadline to submit comments on the proposed rule is Monday, September 10.